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lacked economic reality. According to respondent, because there
was no business purpose behind the asset sale, the transaction
should be ignored for tax purposes and Wysong Medical retains an
equity interest in the assets. Hence, respondent contends that
no deduction is allowed under section 162 for any part of the
rent payment earmarked for Wysong Medical's use of the
aforementioned equipment. See sec. 162(a)(3).
We sustain respondent's position as to the amounts allowable
as deductions for rent. We entertained, at great length,
petitioners' evidence of Wysong Medical's and Wysong Corp.'s
intent to convey to Wysong Medical the right to use more than the
square footage identified in the lease agreements. We remain
unconvinced, however, that petitioners or the two corporations
intended to enter into an agreement other than the one evidenced
by the leases. The leases are clear and unambiguous. Dr. Wysong
had unfettered control over the final terms embodied in the
leases, and he signed both agreements in his capacity as the sole
shareholder of both the lessor and lessee corporations. We are
also unpersuaded that Wysong Medical used more of the Eastman
Building than it was allowed under the terms of the leases, or
that the addition to the Eastman Building's warehouse was
completed during the years in issue. Petitioners' 1992 and 1993
tax returns identify the Eastman Building's total asset cost as
$403,400. If petitioners had incurred construction expenses in
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